272
Toxic Chemicals
using the convenient solvent and cloths for operations that did not require TCE, and
he directed that these materials only be used for the specified purpose. Just 1 wk
later, production of waste rags had dropped by over 80 percent.
Pressure to reduce mercury releases from chloralkali plants has provided an
impetus to replace mercury cells with newer mercury-free membrane cells. This
has resulted in 110 plants making the switch, eliminating over 50 tons/yr in mercury
releases. Much of the cost in the switch has been recovered in improved energy efficiency and increased capacity.
Toxic chemical use reduction planning consists of collecting data on chemicals
used and processes in which they are used; evaluating alternative, less-toxic chemicals
and processes that could reduce higher-toxicity chemical use; determining technical
and economic feasibility of implementing changes; performing a cost-benefit analysis;
and funding of cost-effective projects that will reduce use.
As part of planning, a chemical use reduction plan would be developed and
include, at a minimum, the following:
• Identification of reduction opportunities
• Identification of cost-effective projects
• Establishment of toxic chemical use reduction goals, including time frames
• Documentation of the progress of meeting the established goals
Under a toxic chemical use reduction program, a full plan would be kept on site at
the company headquarters at all times, and a summary of the plan would be submitted to a regulatory agency. The purpose of submitting the plan summary and having
the plan available on site is to confirm that a plan is developed and that the process
identified in the plan is implemented, not for technical review of the plan.
TECHNICAL ASSISTANCE
One study found that larger firms are generally more successful at pollution prevention efforts because they integrate the pollution prevention processes into other existing management activities (e.g., quality teams). Small and midsize firms generally
have fewer internal resources to complete pollution prevention activities and rely
more “on external resources for identifying pollution prevention options. They tend
to look at published literature, trade associations, vendors and technical assistance
programs” (McLees 1995).
A technical assistance program should include three components:
1. Compliance assistance
2. Technology clearinghouse
3. Plant-specific technical assistance
Compliance assistance would focus on helping companies to understand and
comply with the requirements of the toxic chemical use reduction program. As
part of this assistance, data on toxicity of chemicals would be provided, along with
Toxic Chemicals
using the convenient solvent and cloths for operations that did not require TCE, and
he directed that these materials only be used for the specified purpose. Just 1 wk
later, production of waste rags had dropped by over 80 percent.
Pressure to reduce mercury releases from chloralkali plants has provided an
impetus to replace mercury cells with newer mercury-free membrane cells. This
has resulted in 110 plants making the switch, eliminating over 50 tons/yr in mercury
releases. Much of the cost in the switch has been recovered in improved energy efficiency and increased capacity.
Toxic chemical use reduction planning consists of collecting data on chemicals
used and processes in which they are used; evaluating alternative, less-toxic chemicals
and processes that could reduce higher-toxicity chemical use; determining technical
and economic feasibility of implementing changes; performing a cost-benefit analysis;
and funding of cost-effective projects that will reduce use.
As part of planning, a chemical use reduction plan would be developed and
include, at a minimum, the following:
• Identification of reduction opportunities
• Identification of cost-effective projects
• Establishment of toxic chemical use reduction goals, including time frames
• Documentation of the progress of meeting the established goals
Under a toxic chemical use reduction program, a full plan would be kept on site at
the company headquarters at all times, and a summary of the plan would be submitted to a regulatory agency. The purpose of submitting the plan summary and having
the plan available on site is to confirm that a plan is developed and that the process
identified in the plan is implemented, not for technical review of the plan.
TECHNICAL ASSISTANCE
One study found that larger firms are generally more successful at pollution prevention efforts because they integrate the pollution prevention processes into other existing management activities (e.g., quality teams). Small and midsize firms generally
have fewer internal resources to complete pollution prevention activities and rely
more “on external resources for identifying pollution prevention options. They tend
to look at published literature, trade associations, vendors and technical assistance
programs” (McLees 1995).
A technical assistance program should include three components:
1. Compliance assistance
2. Technology clearinghouse
3. Plant-specific technical assistance
Compliance assistance would focus on helping companies to understand and
comply with the requirements of the toxic chemical use reduction program. As
part of this assistance, data on toxicity of chemicals would be provided, along with